State of Oregon Department of Environmental Quality - PDF document

1 State of Oregon Department of Environmen
State of Oregon Department of Environmental Quality Hollingsworth & Vose Fiber Company Air Quality Questions and Answers Emission testing is required if specified by a rule or if it is required for emission factor verification. There was no specific rule that required H&V to verify their emission factors for burning natural gas. DEQ required emission factor verification testing after considericitizen input during the last permit renewal. The test results were very unexpected. Further investigation revealed the unique nature of natural gas combustion in the company’s fiberizers. There are only four other companies nationally that producesimilar products as H&V which limited the availability ofemission data.Q: What are the potential health effects of the higher carbon monoxide and fluoride emissions?A: DEQ does not conduct site specific health studies but relies on the U.S. Environmental Protection Agency (EPA) standards which are based on extensive scientific and technical assessments and undergo extensive reviewThe Clean Air Arequires EPA to set National Ambient Air Quality Standards(NAAQS) for pollutants considered harmful to public health and the environment. he NAAQS are health based standards set by EPA to protect public health and the environment.EPA has set levels called significant emission rates, or SER, for many pollutants. SERare screening levels used to evaluate if emissions are protective of air quality. Emission levels below the SER are considered protective. Emissions above SER do not necessarily indicate they will have a negative impact on air quality, but does require the source to complete a comprehensive analysis to demonstrate that the emissions will be protectiveof human health and the environment.Q: What is the comprehensive analysis required for carbon monoxide and fluorides?A: This is a multistep process. First, the source is required to determine the maximum pollutant levels operating at 100% capacity (24 hrs/day, 7/days week). Next, these levels are then put in

2 to a computer model which predicts the m
to a computer model which predicts the maximum levels in theair surrounding the facility. It should be noted that the predicted maximum levels are always higher than actual emissions and therefore provide a protective safety margin. The maximum pollutant levels are compared to set ambient standards. If they are above the standards, the source must reduce emissions or put on additional pollution controls. There is a NAAQS standard for carbon monoxide. There is no national ambient standard for fluorides. However, there are several states that have establishedambient fluoride standards. The last step in the comprehensive analysis is a review of emission controls. The source must demonstrate that they are controlling their emission with the best available control technology or BACT. H&V currently uses wet scrubbers to clean the exhaust from their emission stacks.H&V has submitted their analysis of carbon monoxide and fluorides in the PSD permit application and the Fluoride Modeling Report. Links to these documents are at the end of this page. DEQ is in the process of completing a comprehensive review of the reports. Q: Will DEQ require H&V to reduce the nitrogen oxide and particulate emissions? A: No. However, thelower nitrogen oxide and particulate matter emissions factorswill result in reduction of the plant siteemission limits for those two pollutants. Q: What enforcement action has DEQ taken to address H&V’s air quality violations?A: DEQ signed a mutual agreement and order with H&V to address air quality violation on December 16, 2015. In the order, H&V agreed to pay the $182,742 civil penalty for not obtaining the proper permits and for not following DEQ’s permitting procedures. H&V was also required to pay $57,526 in back permit fees for the years 1996 to present. Q: Who was involved in negotiating the MAO?A: The MAO was negotiated between DEQ and H&V. Q: What are the next steps in the permitting process for H&V?A: H&V currently operates under an air contaminant discharge

3 permit which DEQ issued in 2008. This
permit which DEQ issued in 2008. This permit is in effect until the new permits are issued. H&V submitted the PSD permit application and Fluoride Modeling Report on January 29, 2016. DEQ is currently reviewing these documents. DEQ has scheduledan informational meeting to provide information,answer questions, and receive public inputon the PSD application on March 30, 2016. After the informational meeting DEQ will begin to draft the permit. Once the permit is drafted, DEQ will put the permitout for public review and commentand schedule a public hearing. After reviewing public input and making any necessary modifications, DEQ will issue the PSD permit. The PSD permit will act as an operating permit until the Title V permit is issued.V will be required to submit a Title V Operating Permit application within 180 days of the issuance of the PSD permit. It can take from four to twelve months to review the Title V permit application and draft the permit. The draft Title V permit will also be put on public notice with public hearing offering an opportunity for public review and comment. Q: What is a PSD permit? A: A prevention of significant deterioration permit is a type of construction permit that involves a thorough analysis of air quality impacts and review of emission controls for a proposed new or modified facility. As part of the permit process, DEQ indentifies the best available control technology that H&V must install to minimize emissions from their modified facility or afacility with increased emissions. This PSD permit is a retroactive constructionand operatingpermit that would have been required in 1996 when the facility last expanded. Q: What is a Title V Operating Permit?A: Title V of the Clean Air Act requires major sources of air pollutants, and certain other sources, to obtain and operate in compliance with an operating permit.Sources with a Title V permit are required to certify compliance with the applicable requirements of their permits at least semiannually. Title V permits ar

4 e required to have adequate testing, mon
e required to have adequate testing, monitoring, recordkeeping, and reporting requirements to ensure compliance with air quality rules and permit conditions. Q: How can I participate in DEQ’s decision making about the new permits?A: There will be several opportunities for people to be involved:DEQ has scheduled an informational meeting on the PSD permit application on March 30, 2016. Details can be found at the link below.DEQ will hold a public comment period and a public hearing when the PSD permit has been drafted.DEQ will hold a public comment period and a public hearing when the Title V permit has been drafted. You may send any questions and concerns to DEQ at hvaqpermit@deq.state.or.us LinksMutual Agreement and Order PSD Permit Application Fluoride Modeling Report : How can I participate in DEQ’s decision making about the new permits?A: There will be several opportunities for people to be involved: DEQ has scheduled an informational meeting on the PSD permit application on March30, 2016. Details can be found at the link below. DEQ will hold a public comment period and a public hearing when the PSD permit hasbeen drafted. DEQ will hold a public comment period and a public hearing when the Title V permit hasbeen drafted. You may send any questions and concerns to DEQ at hvaqpermit@deq.state.or.us nksMutual Agreement and Order SD Permit Application luoride Modeling Report Q: How can I participate in DEQ’s decision making about the new permits?A: There will be several opportunities for people to be involved: DEQ has scheduled an informational meeting on the PSD permit application on March30, 2016. Details can be found at the link below. DEQ will hold a public comment period and a public hearing when the PSD permit hasbeen drafted. DEQ will hold a public comment period and a public hearing when the Title V permit hasbeen drafted. You may send any questions and concerns to DEQ at hvaqpermit@deq.state.or.us LinkMutual Agreement and Order PSD Permit Application Fluoride Modeling Repo